Post­ed by Lin­da Rowings

self fundedTo meet fed­er­al require­ments, large health plans must obtain a nation­al health plan iden­ti­fi­er num­ber (HPID) by Novem­ber 5, 2014. For this require­ment, a large health plan is one with more than $5 mil­lion in annu­al receipts. The Depart­ment of Health and Human Ser­vices (HHS) has said that since health plans do not have receipts, insured plans should look at pre­mi­ums for the pri­or plan year and self-fund­ed plans should look at claims paid for the pri­or plan year. Small health plans (those with less than $5 mil­lion in claims dur­ing the pri­or plan year) have until Novem­ber 5, 2015, to obtain an HPID.

Although this require­ment applies to all health plans, the insur­er will obtain the iden­ti­fi­er num­ber for ful­ly insured plans. Self-fund­ed plans will need to obtain the num­ber, even if they use a third par­ty admin­is­tra­tor (TPA) to pay claims. Plans will be required to use HPIDs in spec­i­fied HIPAA stan­dard trans­ac­tions by Novem­ber 7, 2016.

“Con­trol­ling Health Plans” (CHPs) are required to obtain an HPID. “Sub­health Plans” (SHPs) may obtain an HPID. A CHP is defined as a health plan that either:

  • Con­trols its own busi­ness activ­i­ties, actions, or poli­cies; or
  • Is not con­trolled by an enti­ty that is not a health plan, and if it has one or more sub­health plans, exer­cis­es suf­fi­cient con­trol over the sub­health plan to direct its busi­ness activ­i­ties, actions, or policies.

An SHP is defined as a health plan whose busi­ness activ­i­ties, actions, or poli­cies are direct­ed by a con­trol­ling health plan.

These def­i­n­i­tions were writ­ten with insur­ance com­pa­nies in mind, since they will be the ones obtain­ing and using most of the HPIDs. Apply­ing them to self-fund­ed plans can be a bit con­fus­ing and HHS has not released any guid­ance specif­i­cal­ly explain­ing how to han­dle mul­ti­ple plans offered by a sin­gle employ­er. In the absence of spe­cif­ic instruc­tions, a rea­son­able approach would seem to be to use the same approach as the employ­er uses with its Form 5500 fil­ing. If an employ­er bun­dles all of its group health ben­e­fits into a sin­gle “wrap” plan and files a Form 5500 under a sin­gle plan num­ber, the employ­er should prob­a­bly apply for a sin­gle HPID for all self-fund­ed ben­e­fits under the wrap plan.

Although health reim­burse­ment arrange­ments (HRAs) and health flex­i­ble spend­ing accounts (HFSAs) gen­er­al­ly are con­sid­ered group health plans, HHS has said that these plans usu­al­ly will not need an HPID. An HPID is not need­ed for a ben­e­fit that is not con­sid­ered a group health plan, such as life, dis­abil­i­ty, or a health sav­ings account (although the relat­ed high deductible health plan will need an HPID).

An employ­er will apply for its HPID through the Cen­ters for Medicare and Med­ic­aid Ser­vices (CMS) web­site. Many employ­ers will first need to reg­is­ter and set up a health insur­ance over­sight sys­tem (HIOS) account at https://portal.cms.gov/wps/portal/unauthportal/home/. Note that an indi­vid­ual must have a login before they can reg­is­ter a new user account. To obtain a login, the indi­vid­ual must pro­vide per­son­al­ly iden­ti­fi­able infor­ma­tion (name, Social Secu­ri­ty num­ber, birth­date, home address, and pri­ma­ry phone number).

For more infor­ma­tion on the HPID, down­load UBA’s free pub­li­ca­tion, “Dead­line Approach­ing for Larg­er Self-Fund­ed Health Plans to Obtain a Health Plan Iden­ti­fi­er”.

CMS has pre­pared – and recent­ly updat­ed — step-by-step instruc­tions in both graph­ic and text for­mats in its Quick Guide and it also has pre­pared a short YouTube video – Learn how a Con­trol­ling Health Plan can obtain a Health Plan Iden­ti­fi­er! – that will also walk the sub­mit­ter through the process. There are sev­er­al steps to this process, so it can­not be com­plet­ed in one session.

Detailed infor­ma­tion is avail­able at: http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Health-Plan-Identifier.html and at http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/Downloads/HPOESTrainingSlidesMarchSlideDeck.pdf. Ques­tions may be direct­ed to HHS at [email protected].

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